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Embargoed and Sanctioned Countries
Certain countries, entities (e.g., businesses, foreign governments), and individuals are subject to trade sanctions, embargoes, and other prohibitions under U.S. export control regulations. These sanctions and prohibitions vary widely by country, can be comprehensive or targeted, and change frequently. University research activities are subject to these regulations.
Comprehensively Embargoed Countries
The current comprehensively embargoed countries are: Cuba, Iran, North Korea, Syria, and the Crimean, Donetsk, and Luhansk Regions of Ukraine.
Most activities and collaborations with these countries, entities associated with these countries, and/or individuals from these countries require an export control license. Note: it may take up to six months to obtain a federal export license.
Sanction Lists
For the most recent information on U.S. trade sanctions and embargoes, see the:
- Office of Foreign Asset Control (OFAC) Sanctions Programs and Country Information website
- OFAC Specially Designated Nationals and Blocked Persons List (SDN).
Restricted party screening conducted by the U-M Export Control Office evaluates individuals and entities against various government lists under the Department of Commerce’s Consolidated Screening List. See the "Which Restricted Party lists does U-M screen against" FAQ for additional information.
What U-M Researchers Should Do
Contact the U-M Export Controls Office before:
- Traveling to any sanctioned country for any University business purpose, including research.
- Collaborating with an entity/individual located in a sanctioned country or from a sanctioned country, but located in the United States, including research collaboration.
- Providing online educational courses to students located in sanctioned countries.
- Initiating or approving telecommuting agreements in sanctioned countries.
- Participating in a conference (either in-person or remotely).
- Sending or receiving physical items (research samples/material).
- Transferring funds to a sanctioned country or receiving funds from a sanctioned country.
Before initiating any activity involving a sanctioned or embargoed country, entity, or individual, review the Department of Commerce’s Know Your Customer Guidance to determine if there are potential “red flag indicators.” The U.S. government considers it your responsibility to be aware of who you are collaborating with and whether any export controlled prohibitions apply.
How Does the Export Control Office Help You?
The Export Controls Office will assist you with:
- Determining if the research activity requires an export license, license exemption, license exception, or if a general export license exists under the applicable regulation(s).
- Applying for a license, as applicable.
- Verifying the export classification for export controlled items.
- Conducting Restricted Party Screening and interpreting the results.
FAQs
U.S. export control regulations also identify certain countries that are subject to a comprehensive embargo or targeted sanctions.
Definitions:
- Comprehensive embargoes prohibit all exports/imports and other transactions without a license or other U.S. government authorization.
- Targeted sanctions are prohibitions on trade in specified goods, technologies, and services with specific organizations (including foriegn governments) and persons.
Resources:
The list of countries per regulation (i.e., ITAR, EAR, and OFAC) and the sanctions change. Use the following links to the federal resources to obtain the most current information.
- ITAR: Country Policies
- EAR: Country Chart (PDF)
- OFAC: Sanctions Program and Country Information
Restricted Party Screening (RPS) is a service provided by the U-M Export Controls program that verifies whether an organization (e.g., company or university), individual, or country has had its export privileges restricted or revoked per the U.S. Departments of State, Commerce, or Treasury and is listed on any of the federal restricted party lists. RPS is required by the federal government and is a critical component of U-M's efforts to prevent violations of U.S. Export Control laws. U-M uses a software program that checks all of the federal lists simultaneously.
Questions?
Questions? Contact the Export Controls Office at: exportcontrols@umich.edu